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Breaking the Code

by Edsel W. Ford, Jr.
Reprinted with permission from FAA Aviation News

When does a group of parts or a machine that looks like an aircraft really become an aircraft? Is it when the last rivet is driven? No. Is it when the last piece of masking tape is removed? No. Then it has to be when it is issued an airworthiness certificate'that has to be when it becomes an aircraft. No again. So, when does it become an aircraft?

The machine becomes an aircraft at the time of registration with the Federal Aviation Administration's (FAA) Registration Branch, AFS-750, in Oklahoma City. AFS-750 will assign a registration number (N-number) and a manufacturer's code. Now the FAA recognizes the machine as an aircraft no matter how complete. This is when it becomes an aircraft.

The Registry receives paper work from the builder of the aircraft and as-signs a manufacturer's code and issues an N-number. Before light-sport aircraft the registration process was simpler. An aircraft owner generally had a type-certificated aircraft or an amateur-built aircraft and the manufacturer's code pretty much stayed in the background. Now the FAA has added light-sport aircraft and increased the possibilities of how registration and certification can be accomplished. This process of registration has normally been transparent to an FAA aviation safety inspector or designated airworthiness representative (DAR) who will issue the certificate of airworthiness. However, FAA inspectors and DAR snow need to look to this code to deter-mine the type of airworthiness an aircraft can receive.

When the Registry assigns an N-number and enters the manufacturer's descriptive code into its computer system, this is the first step in the FAA's ability to track and identify that individual aircraft, issue safety information, complete reports, and answer questions. For example, you have a safety bulletin that needs to be sent to the owners of light-sport powered parachutes. How do you accomplish this? The process starts by researching the Registry database for certain codes assigned to each affected aircraft.

This code started with the first step in the registration process, when the builder or owner submitted an Application for Registration (FAA Form8050-1) and the affidavit of ownership. Here is how it works.

A new aircraft builder or owner submits to the Registry an Application for Registration (FAA Form 8050-1) and either an Affidavit of Ownership for Experimental Aircraft, Including Amateur-Built Aircraft and Other Non-Type Certificated Aircraft (FAA Form 8050-88) or an Affidavit Of Ownership for Experimental or Special Light-Sport Aircraft (FAA Form 8050-88A). The process of coding the aircraft starts with the information provided on these forms. The FAA Form 8050-88 submitted to the registry will have as-signed to it a manufacturer's code be-ginning with the numbers 056. The remaining numbers in the code will further identify the aircraft, but we are only going to look at the first three numbers in the code. If the FAA Form 8050-88A with the second option checked is submitted, the aircraft will be assigned a manufacturer's code beginning with 059. This indicates an experimental light-sport aircraft (ELSA) code. If the first option is checked, a code beginning 060 for special light-sport aircraft (SLSA) code is assigned. The owner makes the determination on whether the aircraft is going to be either amateur-built or light-sport special or light-sport experimental when choosing which affidavit form to use and marking the options on the form. The owner may not know the importance of the choices, but by making the choices the owner made the de-termination on what airworthiness certificate the aircraft will be able to receive.

(FAA Form 8130-6

The information submitted on the Application for Airworthiness (FAA Form 8130-6) only further defines the code. It does not determine if the aircraft is an amateur-built or a light sport. Most inspectors and DARs think that the 8130-6 is the assignment of the classification of amateur-built or light sport, but that is not correct. It was done with the submission of Form 8050-88 or 8050-88A as previously mentioned. In fact, this is only where the coding for the aircraft is further defined.

To further define the aircraft, look at section II, 'Certification Requested' on Form 8130-6. This is where the aircraft will receive another part of the code. The first block that has to be checked for amateur-built or light-sport aircraft is B, special airworthiness certificate. If you then checkbox 4, 'experimental,' and sub-box 8, 'operating light sport,' and sub-box 8A, 'existing aircraft without an air-worthiness certificate and does not meet 14 CFR section 103.1;' this aircraft would get an airworthiness code of 48A. This airworthiness code can only exist in manufacturer's code 059, experimental light sport, so this means FAA Form 8050-88A's second option is checked. What if I checked box 9, 'light-sport,' and then checked 'airplane?' It would have an airworthiness code of 9A. This would mean that I need the first option of FAA Form 8050-88A checked to receive manufacturer's code 060. The experimental amateur-built would have block 4 and sub-block 2 checked for an air-worthiness code of 42 and this could only exist on an FAA Form 8050-88 and a manufacturer's code of 056.

What does all this mean to the inspector or DAR performing a certification of an aircraft? It means that each needs to look at the registration documentation to determine what blocks can be checked on the 8130-6. We need to set some rules. Use Form 8050-88 and the options would be limited to block 4, experimental, sub-block 2, amateur-built. Use Form 8050-88A with the second option checked and the blocks would be limited to 4, experimental, and sub-block 8, operating light-sport, then you have two choices either 8a, 'existing fleet,' or 8b, 'kit built.' Since the kit standards have not been completed at this time, option 8b is not available. Let us look at a Form 8050-88A with the first option checked. This is the most complex. However, a manufacturer of a light-sport aircraft can only accomplish this. The manufacturer would check block 9, light sport, then check the class of aircraft. However, in the case of a manufacturer operating a light-sport aircraft for research and development or some of the other variations in the sub-block under experimental, the aircraft would be registered using the 8050-88A with the first option checked. It would have a manufacturer's code of 060, but an airworthiness code of 41, research and development, 43, exhibition, or 46, market survey but never 42 amateur-built.

With all this in mind the inspector or DAR should start the certification work by researching which affidavit was used. This will tell the inspector or DAR if the certification requested can be accomplished. If the applicant says at the last minute, 'I want this air-craft to be an ELSA instead of an amateur-built,' and the applicant had submitted an 8050-88, the inspector or DAR can have the applicant contact the Registry for instructions to set aside the initial affidavit and submit an 8050-88A to amend the registration record. The applicant should have submitted FAA Form 8050-88A with second option checked. This way the code will be correct, and the FAA can better serve the public and promote safety.

For more information on aircraft registration, see the FAA Aircraft Registry Web site at

Edsel Ford is Aviation Safety Inspector Airworthiness in Flight Standards' Light Sport Aviation Branch, AFS-610.

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